During the fiscal year 2024, Logista implemented a compliance program concerning competition defense, in line with the guidelines established in the National Commission for Markets and Competition (CNMC), guide on compliance programs regarding competition defense norms, dated June 10th, 2020, and the UNE 19603:2023 about standard on compliance management systems in relation to free competition by the Spanish Association for Standardization, dated November 22nd, 2023.

As the central axis of this program and an explicit expression of its commitment to a culture of compliance and rejection of illegal activities concerning competition, on July 24th, 2024, the board of directors of Logista approved the competition policy, which is part of the competition compliance program and is also integrated into Logista’s compliance system.

The competition policy outlines the functions of the various participants in the competition compliance program, including the board of directors, the audit, control, and sustainability committee, the executive committee, the compliance committee, and other members of Logista, assigning to each of them their respective responsibilities and duties in relation to the program.

The competition policy provides a detailed description tailored to Logista’s activities of the different behaviours that could constitute a violation of competition regulations to express its total rejection and prohibition. The described behaviours include the following:

• Horizontal conduct (price fixing, client distribution, information exchanges, etc.).
• Vertical conduct; mainly resale price-fixing agreements.
• Abuse of dominant position.
• Business acquisitions and mergers.

To ensure its public awareness, the competition policy is accessible to all interested parties through its publication on the intranet and the corporate website www.logista.com. Additionally, its content has been included in mandatory training programmes for Logista members.

Furthermore, the competition compliance programme also includes the following elements (in addition to those that are common to Logista’s compliance system, such as the whistleblowing channel):

• Competition risk assessment, which is reflected in the inherent risk map concerning competition, from which the gross or inherent risk associated with the various sanctioning types is obtained.
• Internal controls, both general and specific, are established to mitigate the competition risks previously identified, thus obtaining the risk and control matrix in competition matters.
• Disciplinary regime.

On November 7th, 2023, the board of directors approved Logista’s human rights policy, which reflects the company’s commitment to human rights and its contribution to promoting a respectful, integral, and egalitarian society by strengthening social commitment and equal opportunities.

On May 7th, 2024, the board of directors approved Logista’s due diligence policy in the supply chain in terms of human rights and the environment, to comply with the duty to identify, prevent and manage potential risks present in its supply chain in relation to human rights and the environment with the aim that relations with suppliers, agents, business partners and third parties are based on principles that guarantee internationally recognized fundamental rights.

It should be noted that the mention of the environment refers to those cases where an alteration in it could imply an impact on human rights.

During the fiscal year 2024, Logista has continued to develop its training plan on the compliance system for its employees, including both online and in-person training on the main internal policies and procedures on these matters, including training on the code of conduct, the anti- corruption and anti-bribery policy, and the criminal risk prevention manual.

The training program also includes a series of informational videos about these policies and procedures, which were published on Logista’s intranet and are available to all its employees.

Additionally, two in-person training sessions on competition matters were held for the group’s executive committee and certain executives of Logista and its subsidiaries, aiming to increase their knowledge of the applicable legal regime and their awareness in this area.

The compliance committee is the collegiate body with autonomous and independent powers of initiative and control, embodying the highest level of supervision, oversight, and control of the functioning and compliance of Logista’s compliance system.

The compliance committee is composed of representatives from the following corporate areas:

• Legal advisory, whose representative will chair the committee as compliance officer.
• Internal control, whose representative will act as secretary.
• Operations.
• Human resources.

It reports directly to the audit, control, and sustainability committee, which oversees the functioning and compliance with Logista’s organizational model.

Logista’s internal information system includes a whistleblowing channel as the ideal and essential tool for preventing and enforcing the guidelines, principles, and ethical values, as well as the laws and internal regulations adopted and applicable to Logista, in order to facilitate communication or information from its members (directors, administrators, legal representatives, executives, employees, or those subject to Logista’s authority) and legitimate third parties (shareholders, contractors, subcontractors, suppliers, interns, trainees, job applicants, former employees, etc.) regarding any illegal, irregular, or unethical conduct by Logista.

In the 2023 fiscal year, the whistleblowing channel policy was updated to align with the standard UNE-ISO 37002:2021, of whistleblowing channel management systems as well as the requirements of Law 2/2023 of February 20th, which regulates the protection of individuals who report regulatory breaches and anti-corruption efforts.

Additionally, during this fiscal year, a secure online platform for the communication of complaints of bad practices, was implemented, publicly accessible to all interested parties via the link provided on Logista’s corporate website Logista which enhances the security, confidentiality, and anonymity mechanisms of the complaints and the investigation procedure, providing even greater security to Logista’s internal information system.

The communications submitted through the whistleblowing channel must concern behaviours, actions, omissions, or acts that constitute a violation, non-compliance, or conduct contrary to the ethical principles and values, laws, code of conduct and other internal regulations applicable to Logista, defined as “malpractices.” Specifically, communications may be made about malpractices that constitute or may constitute breaches of European Union law as defined by the applicable legislation, as well as serious or very serious administrative violations or criminal acts.

The communications received through the whistleblowing channel must fall into the following categories,withoutprejudicetotheexistenceof the reported malpractice:

• Violation of human rights
• Corruption or bribery
• Money laundering and terrorist financing
• Discrimination, harassment, or other labour-related issues distinct from human resources matters
• Breach of environmental regulations
• Financial and accounting irregularities
• Non-compliance with customs and tax requirements
• Others

In the financial year ended 30 September 2024 28 complaints were received of which 93.0% were received by email, 3.5% by the new online platform and 3.5% by communication from a worker. In the 2023 financial year, we received 12 complaints, of which 91.6% were received by email, and 8.4% by post.

In Spain, complaints can be made anonymously. In other countries, complaints can also be made anonymously unless the applicable national legislation requires the complainant to identify themselves. Nevertheless, in 2024, the person who filed the complaint identified themselves in 78.6% of the cases compared to 91.6%of the cases in 2023.

Logista’s whistleblowing channel policy establishes that during the investigation procedure of malpractices, the following principles and guarantees must be adhered to:

• Confidentiality
• Non-retaliation
• Guarantee of actions
• Fundamental rights presumption of innocence
• Guarantee of proportionality, precision and security of information and personal data

The following categories represent the complaints received during the fiscal year ending on 30 September 2024:

The complaints received and assigned to the category of corruption and bribery refer to bad practices that may have been carried out to the detriment of Logista, in no case for its benefit.

During the fiscal year 2024, there were no complaints received regarding matters related to respect for freedom of association, the right to collective bargaining, discrimination in employment, forced labor, child labour or human rights violations vs. 3 received in 2023.

The assignment of the complaints to these categories does not imply recognition of the concurrence of the facts denounced.

In Spain, the management and development of the investigation procedure until its resolution is the responsibility of the compliance committee. In other countries, the investigation procedure and its resolution will be carried out by the corresponding local compliance unit in the country where the reported events took place.

Human rights are a material aspect of Logista; as such, we ensure their compliance.

In the sustainability policy, compliance with regulations through responsible practices in key areas such as the prevention of illegal conduct, respect for human rights, and diversity is established as one of the main values on which Logista’s business model is based.

99% of Logista’s employees operate under updated agreements and have access to workers’ committees and union representatives, allowing workers to freely access their representatives at all times. Various independent unions periodically exercise their right to meet. Operations are carried out with full knowledge by workers of the right to collective association, which is an essential tool for compliance with ILO provisions.

Compliance with the provisions of the fundamental ILO conventions and the Principles of the United Nations Global Compact is implemented in Logista through the following mechanisms, monitored by the compliance committee and other supervisory bodies:

Code of conduct: Establishes that Logista is committed to protecting and respecting human rights in all its operations, recognizing the need to avoid infringing on the human rights of others and to adequately address adverse impacts on human rights that may occur in our activities, explicitly stating that:

• All Logista members are obliged to respect the dignity and human rights of all other members and third parties with whom they come into contact during the course of their activities.
• We act with full respect for the fundamental right to freedom of association, managing relations with workers’ representatives and unions smoothly and transparently. All Logista employees have the right to decide whether to join a union or have recognized representation in accordance with applicable legislation.
• We will never use or allow the use of forced labour or human trafficking, nor will we employ minors under the age of 16, under the local minimum employment age, or under the compulsory schooling age (whichever is higher), nor will we employ minors under the age of 18 to perform any work considered dangerous or that could harm their health or safety.
• We require suppliers to meet their labour obligations with their employees, respect the labour and union rights of their employees, and pay wages that meet the legal minimum or the applicable collective agreements, whichever is higher. Human trafficking or forced labour is expressly prohibited. We also require our suppliers to promote integrity, teamwork, diversity, and trust, ensuring a fair, respectful, and harassment-free workplace, promoting a positive culture of health and safety, and prohibiting unacceptable or potentially dangerous behaviour at work.

Human rights policy: Logista seeks to embody the ethical principles it promotes, as well as exemplary business behaviours in line with the best existing practices in human rights. In line with this objective, the new human rights policy was approved in 2024, a policy that is based on the main international bases of reference established within the United Nations, such as:

• The United Nations Global Compact.
• The Universal Declaration of Human Rights, which constitutes the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, and the Covenant on Economic, Social, and Cultural Rights.
• The fundamental rights in the eight main conventions of the International Labour Organization (ILO), as established in the Declaration on Fundamental Principles and Rights at Work.
• The United Nations Guiding Principles on Business and Human Rights (UNGPs).
• The European Social Charter.

Taking into account the potential effects that Logista’s global activity may have on the groups involved, the human rights policy explicitly commits to the following:

• • Commitment to employees, ensuring that the relationship with them is governed by principles of justice, equity, dignity, and respect, guaranteeing the following rights:

• • • Fair and favourable working conditions
    • Equitable and satisfactory remuneration
    • Work-life balance and rest
    • Freedom of association and collective bargaining
    • Freedom of expression
    • Respect for diversity, inclusion, and non-discrimination
    • Health, safety, and well-being at work
• Commitment to the supply chain and modern slavery, ensuring that suppliers, business partners, and other third parties that are part of Logista’s supply chain observe strict compliance with human rights through sustainable supply chain management and internal due diligence regulations.
• Commitment to society and local communities, promoting the following rights:

• • Minority and community rights
  • Fight against corruption and bribery
  • Right to a clean, healthy, and sustainable environment

Finally, the human rights policy establishes a governance model that recognises the competence of Logista’s board of directors to explicitly state the company’s commitment to human rights and the environment, assigning the executive committee the responsibility to define the strategic human rights and environmental plans in Logista’s supply chain within the framework of the company’s sustainability strategic plan.

To ensure its accessibility and public awareness, the human rights policy is available to all interested parties through its publication on the intranet and the corporate website www.logista.com.

Due diligence policy in the supply chain on human rights and the environment: During this financial year, Logista has also approved the due diligence policy in the supply chain in the field of human rights and the environment. This policy establishes due diligence principles and standards of conduct aimed at promoting that suppliers, agents, business partners, and/or third parties in relationships with Logista respect human rights, expressing the principle of “zero tolerance” towards those from whom motivated suspicion or reasonable indications of human rights violations exist, such as the following:

• Any form of torture or cruel, inhumane, degrading treatment, and/or related to modern slavery.
• Any form of forced labour, defined as any kind of work or service required of an individual under the threat of punishment and for which the individual has not voluntarily offered.
• Any form of child labour, understood as the employment of minors under the local minimum employment age or under the compulsory schooling age (whichever is higher), or of minors under the age of 18 to perform any work considered dangerous or that could harm their health or safety.
• Other serious human rights violations and abuses such as widespread sexual violence.
• War crimes or other serious violations of international humanitarian law, crimes against humanity, or genocide.
• Any form of discrimination or unequal treatment based on race, religion, gender, age, disability, nationality, sexual orientation, and/ or political opinions.
• Serious violations of labour regulations that involve unsafe and dangerous environments for workers.
• Obstruction of freedom of expression, thought, opinion, and information, reducing the diversity of opinions.
• Violation of measures aimed at achieving a healthy, clean, and sustainable environment.

To prevent these behaviours, the due diligence policy in the supply chain on human rights and the environment foresees its development through a due diligence procedure consisting of six phases:

1. Cross-sectional integration of due diligence.
2. Identification of real and potential adverse impacts.
3. Prevention of adverse effects.
4. Definition of measures to end adverse effects.
5. Establishment of a grievance procedure.
6. Approval of a monitoring and reporting procedure.

The due diligence policy in the supply chain on human rights and the environment is available to all interested parties through its publication on the intranet and the corporate website www.logista.com.

To reinforce the due diligence measures to be developed by the group during this fiscal year, an external provider was contracted to implement an online platform for third-party risk assessment. This platform allows the assessment of the risk associated with suppliers and third parties of the group in areas such as:

• Exposure to risks of corruption, human rights violations, or international sanctions.
• Identification of open or closed legal proceedings related to fraud, corruption, bribery, and other crimes.
• Identification of possible connections or affiliations with politically exposed persons (PEPs), companies with public participation (SOW), and any links with other close family members or associates (RCA).
• Tax havens: analysis of inclusion in lists related to tax havens.
• Compliance with sustainability obligations (ESG).
• Cybersecurity risk.

General behaviour principles for suppliers: These set out the minimum standards and basic behaviour norms that should govern the activity of suppliers both in their relationships with Logista and concerning their employees or other third parties involved in the development of their activity. During this fiscal year, a specific obligation was included for Logista’s suppliers to promote respect for human rights both in their own organisation and in their business relationships with third parties.

All suppliers must be aware of and accept the behaviour principles, which are mandatory for contracting with any of Logista’s companies. The company may terminate its contractual or commercial relationship with any supplier that does not comply with the behaviour principles or, upon breach, does not take the necessary measures to rectify the non-compliance.

Procurement standard: This standard establishes that all suppliers must be certified and have a notable economic-financial and technical capacity. Additionally, contracts will be governed, among other things, by the principle of ethical and professional conduct, whereby suppliers must behave accordingly. In particular, the obligation to evaluate suppliers in ESG matters for purchasing processes that exceed a certain established threshold has been introduced in the procurement standard. These sustainable criteria have a weight of 15% of the total valuation of each supplier, representing a relevant criterion when making new hires.

The company’s bodies responsible for the development and implementation of the risk control and management system are:

In line with our commitment to digitalization and the use of technology, during the year we implemented the SAP GRC Risk Management system to integrate Logista’s risk management model.

This tool manages Logista’s risk model through its various functionalities, which will enable us to execute the different phases of risk management, from identification, analysis and evaluation to treatment and follow-up.

• Objectives and context: Logista defines its strategic objectives and the environment in which it operates, both from an internal and external point of view, taking into account the interests of its stakeholders, which affects the way it manages risks. It also defines its risk appetite, i.e., the level of risk that the company takes as acceptable during its activities, as well as its risk tolerance.

• Compliance with all rules, laws and regulations and taxation by which it is affected.

For those that allow you to:

• achieve the strategic objectives determined by Logista while keeping the level of uncertainty under control.
• maintain the highest level of assurance to shareholders.
• protect Logista’s results and reputation.
• defend the interests of shareholders, customers, and manufacturers.

• In the face of technological risks that could materialize as part of Logista’s strategy of providing logistics services with high added value and, therefore, with a high level of technological progress.

During the first quarter of the year, the management committee made its proposal for risk appetite, to the board of directors, established both, under quantitative (economic-financial) and qualitative (non-financial) criteria, and after deliberation by the audit, control and sustainability committee. The board of directors has approved and validated this risk appetite.

• Risk detection: Identification of potential events that could pose a threat to Logista’s objectives.
• Risk analysis: The risk is defined according to its causes and factors, as well as by consequences for Logista if the risk materializes. It can be classified into the following categories which include ESG risks.

• Risk assessment: The severity of the risk is estimated, in order to prioritize those situations of greatest concern, and the mitigation measures established in Logista to reduce these identified risks are evaluated, obtaining as a result the residual risk, as well as the speed at which the risk is estimated to materialize, which allows determining the position of each risk within the general risk appetite and tolerance scheme. The criteria for evaluating risk impact has the following classification:

• Economic-financial
• Regulatory compliance
• Health and safety
• Impact on processes
• Reputational strategic
• Context for Logista

Risk treatment: Logista’s response to risk is analysed and categorised among the following five types of responses, which are detailed in the following table. In addition, action plans are defined when it is necessary to take additional measures for adequate risk management.

• Process monitoring and review: The risk management process is continuously monitored and reviewed, with special emphasis on emerging risks, evolution of risks already identified, as well as completed and materialized risks.
• Information and communication: Relevant risk information to and from all levels involved in Logista’s risk management is managed through the risk management tool.

In this regard, the management committee discussed the main risks and their response plans on a quarterly basis, as well as the most relevant risks by business (regardless of their position on the corporate risk map), which facilitates lower- level decision-making, and approved Logista’s risk map. It defined a proposed risk strategy and risk appetite, both globally and for each of Logista’s business lines, which was approved by the audit, control, and sustainability committee.